y @ ge [All redactions on this page made pursuant to lexemptions (b)(6), (b)(7\(C) & (b)(7)(F) unless lotherwise indicated ai DEPARTMENT OF THE TREASURY WASHINGTON, D.C, 20220 er] es This responds to your request of September 20, 2007, submitted to the Office of Foreign Assets Control ("OFAC") for the reexamination of your client's listing by OFAC as a Specially Designated Narcotics Trafficker ("SDNT") pursuant to Executive Order 12978 of Octaber 21, 1995 ("Blocking Assets and Prohibiting Transactions With Significant Narcotics Traffickers"). In order for OFAC to properly evaluate your client’s petition, he should provide his own. detailed narrative responses to the following requests for information, in a signed original statement submitted with documentation in support of the answers given. Original statements and documents prepared in Spanish should be accompanied by English translations. What is your clieit’s relationship with the following individuals and entities? Ifhe has terminated his relationship with any of the individuals and/or entities listed below, please provide documentary evidence of such termination: Loon oa R-014222[All redactions on this page made pursuant to lexemptions (b)(6), (b)(7)(C) & (b)(7)(F) In addition, please also provide any other information, including the existence of any relationships with SDNTs other than those listed above, that may be relevant to your client's petition, A list of SUNT Principal Individuals, designated ue to their significant roles in Colombian narcotics trafficking, is enclosed. IfOFAC does not receive a response from within the next 90 days, we will assume that you do not wish to proceed. Your olient’s case will be closed and the petition for temoval from the SDNT list will be denied. 2 LooR a &R- 014723‘We may pose additional questions and documentary requests as we proceed, ‘Thank you for your cooperation in this matter. Please direct any questions to the Office of Foreign Assets Control, Designation Investigations: Office of Foreign Assets Control U.S. Department of the Treasury ATTN: Designation Investigations 1500 Pennsylvania Avenue, N.W. Washington, D.C, 20220 Sincerely, Paul Que a[8fot Pau! Lurie Acting Assistant Director Designation Investigations Office of Foreign Assets Control Enclosure toon a ant orazes(eva) DEPARTMENT OF THE TREASURY WASHINGTON, D.C, 20220 Licese xo. Narcotics Trafficking Sanctions Regulations LICENSE. (crantad undge the authoetty O€ Section 203/a) (2) of antamatonsl Reaxponcy Kconeate Powers Act, [60 U.5.c. § 17084) (211, tha National forgencien Act, (80 U-a-6, 89 A60I-168i), ‘nwcutive ooder St576 oe Detcber 2h, 1995, 60 xed. Hag. 54579 (october 24, i993), and 3L°C.-R, Parts’ SOL end £35.) (tho "ticensee") ()(6), (BM7)C) & (OTF) 4, Based on your letters of Maren 8, 2005 and May 6, 2005 to the Office of Foreign Assets Control (the "Application"), the transactions and activities delineated on ine reverse hereof are hereby authorized 2. This License is granted upon the statemente and representations nade in the Application, otherwise filed with or made to the fzeasury Department ‘os a supplenent to the Application, or based on information available to the Treasury Depertment, and is subject to the condition, anong others, that the Licenses conplies in all respects with ail regulations, rulings, orders, and instructions issued by the Secretary of the Treasury under the authority of Section 203 of the internatlonal Bnergency Econonic Powers Act, $0 U.S.C. § 1702, the National Emergencies Ast. "30 0LS.c. 69 1601-1681, and the terns of this License. The Licensee shall furnish and make available for inspection any relevant 2 of the Treasury, or any information, records, or zeporte requested by the Secret: other duly authorized officer or agenoy. 4, hig License expires on May 27, 2006, ie not transferable, and is subject to the provisions of Executive Order 12978 of October 21, 1995, 60 fed. eg. 54573 (October 24. 1995), 31 C.F-R, Parts 501 and 536, and rulings issued parouade thereto, This License may be revoked oF modifies at any time at the discretion of the Secretary of the Treasury, If this License was issued as a result of willful misreprotontation, it may, at the discretion of the Secretary of the Treasury, be declared void from the date of les issuance or from any other date, 5. This License does not excuse compliance with any law or regulation adsinietered by the Office of Foreign Aescta Control or another agency {including feporting requiresents) applicable to the transactions herein licensed, nor does if release iicensee cr third parties from civil or criminal liebility for violation of any iguiation ragued by direction and on behalf of the Secretary of tha Treasury: OFFICE OF FOREIGN ASSETS CONTROL : Pi dhact Wd, Woscieze i Director au fe. § 1705, 10 V8.6. 6 2002, and 22 GuF.R, § 596.701 for Provisions Feisting te. posal toon a R-01z25[All redactions on this page made pursuant to lexemptions (b)(6), (b)(7)(C) & (b)(7)(F) unless (eye) lothenwise indicated ices: No a! Page 2 of 2 sRcSI0N 1 = AUBVOR:2ARTON: (a) Subject co the conditions and 14 ated herein, the Licensee ie hereby authofized to receive payment. from fiche *client*), oF trom the Client's: sereign counsel, fer Tegal ‘Services authorized by § 536.506(b) of the Narcotics Trafficking Sanctions Reguiasions, 31 C.F.R, Part 536 (the “Regulations”| Qo) Any transfer of funds through the U.S. financial system pursuant to the authority set fortt above should reference the number of this License to avoid the blocking or rejection of the transfer. SECTION 2 - CONDITIONS: (a) It is a condition of this License that payrents the Licensee for professional fees end oxpensea authorized by thie License mast originate directly from the Client, or fvon the Client’s foreign counse!, and not from a source within the United States or within the possession or contro: cf @ G.8. person, inclucing its overseas branches, and mast not be made fron a blocked account or from other blocked property. (b) It is a further condition of this License that a copy of this License be submitted to the relevant cour: or any other decision-making bedy or forun. SECTION 3 ~ WARNINGS: (a) This License does not authorize the transfer of any blocked property, the debiting of any blocked account, the entry of any judgment pr order that effects a transfer of blacked property, or the execution of any judgment against peoperty blocked pursuant to any Executive order or Chapter V of ritle 31 of the C.F.R., including the Regulazions (bo) Except as expressly authorized by tho terns of this License, or otherwise by the Office of Foreign Assets Control, nothing in this License authorizes the receipt of funds or other property, directly or indirectly, from any entity or individual whose property or interests in property are blocked pursuant. to any Executive order or chapter V of Title 31 of the C.F.A., including aay entity or Individval naned or designated as « Specially Designated Narcotics treffickse pursuant to Executive Order 12978 or the Regulations, (c)_ Nothing in this Licenge authorizes the provision of services or the receipt Of tees or reimbursonent of expenses other than for the purposes delineated in SECTION 1, above, SECEION 4 - REPORTING REQUIREMENTS: (a) Section 501,501 of the Repoxting and Procedures Regulations requires that records on each transaction subsect to thie Licenso be maintained and evailable fer examination for a minimum of five yesrs following the transaction dater (b)_ See 31 C.F.R, 9 501.605 regarding reports on Litigation, arbitration, Alepute resolution preceedines. and SECTION 5 - PRECEDENCE: The authorization contained in thie License ia linited to the facts and circungtances specific to the Application. Locka &R- 014226[All redactions on this page made pursuant to lexemptions (b)(6), (0)(7)(C) & (b)(7)(F) unless lotherwise indicated DEPARTMENT OF THE TREASURY WASHINGTON, B.c. 20220 ee Narcotics Trafficking Sanctions Regulations LICENSE AMENDMENT (Granted under the authority of 50 U.S.C. §§ 1701 et seq, Executive Order 12978 of October 21, 1995, 60 Fed, Reg, 58579 (October 24, 1995), and 31 CER, Parts 301 snd $36.) To: (tite “Licensee”) Based on 2 letter dated August 22, 2006 from the Law Offices of Jon bebe of io the Office of Foreign Assets Contsol (he “Application, fon otterwite available to orien ‘Assets Control, License No. fSMIMM is hereby amended and the transactions and activities delineated inthis License Amendment ae hrey ute Syray 2, Thig License is granted upon the stamens and representations made i the Application or otherwise filed with or made to te Treasury Departinent as 2 supplement to the Application and iz subject to the condition, among others, thatthe Liceusce complies in all respects with. all repulations, rungs, orders, and instructions issued by the Seeretary of the Tessury under the suthority f Section 203 of te Intemational Emergency Economic Powers Act, $0 U.S.C. § 1702, and the terms ofthis License, 4. The Licensee shal furnish ard make available for inspection any relevant information, records, or reports requested by the ‘Sceretay ofthe Treasury or any othcr duly authorized officer or agency. 4, This License expires November 30, 2007, isnot transferable, and is subject tothe provisions of Executive Order 12978 of October 21, 1995, 60 Fed, Keg. $4579 (October 24, 1995), 31 GFR. Parts 501 and $36, and nulings issued purovent thereto, ‘This License may be revoked or modified at any time atthe discretion of the Secretary of the Treasury. If this License wag dssued ab a result of willful misropresentation on the part of the applicant, it may, atthe discretion of the Secretary oF the ‘Treasury, be declared void from the date of is issuance or ftom any athe dae 5, This License does not excuse compliance with any law or regulation administered by the Office of Foreign Assets Corto! or another ageney (including reporting requirements) applicable tothe transaction(s) herein licensed, aor does it release License(s) ‘oc tied parties from civil o criminal liability for violation of any Jaw or regulation, Isued by direction and on betalf ofthe Secretary ofthe Treasury: OFFICE OF FOREIGN ASSETS CONTROL ily Chief TEEPA Licensing Section ‘Complex Transactions ‘Acention is directed to, ier alia, 50 USCC, § 1705, 18 USC. § 1001, and 31 CER. § 536,701 for provisions relating to penalties. Look oar o1azer